Failure to Collect and Pay Over Tax, or Attempt to Evade or Defeat Tax or Supply Information by DISC or FSC

ID: CCA_2010040707191242 Number: 201017047
Release Date: 4/30/2010
Office: ---
UILC: 6672.00-00
From: ---
Sent: Wednesday, April 07, 2010 7:19:53 AM
To: ---
Cc: ---
Subject: RE: Initial Statute Review Standards in TFRP cases
Good morning: Look at IRM 5.7.6.1.6. This seems to state pretty clearly that as long as the protest is filed within the appropriate time frame, it will be considered a timely appeal even if it is incomplete and efforts to perfect the appeal are unsuccessful. The protest should still be sent to Appeals as a timely appeal. At that point, Appeals will deal with the case according to their rules.